Resulting from a buildup of hazardous waste in European Union landfills, the Restriction of Hazardous Substances (RoHS) directive was adopted by the EU in February 2003 and went into effect July 1, 2006.
The directive restricts the usage of six hazardous materials—lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBBs), and polybrominated diphenyl ether (PBDE)—in the production of electronic and electrical equipment. However, the regulations are merely guidelines, not laws.
With the exception of cadmium, which is limited to 0.001 percent or 100 ppm, the maximum concentrations are 0.1 percent or 1000 ppm by weight of homogeneous material.
The limits do not apply to the weight of the finished product or component. Rather, they apply to any substance that can be mechanically separated. In other words, if a wire inside a radio does not meet the requirements, the entire radio will fail.
RoHS is far from a universal standard. In the EU, there are exemptions for such products as medical devices and telecommunications equipment. China has RoHS regulations, but only for labeling and packaging. In the U.S., individual states, like California, have implemented their own form of RoHS standards.
Despite the complexity of varying standards, most manufacturers are doing well in terms of compliance.
According to Dave Bender, corporate director for RoHS at Tyco Electronics, “There are pockets of noncompliance, but for the most, multinational companies and big OEMs have taken the regulations seriously and have applied them to their supply chain.”
Jeff Shafer, senior vice president of products for Newark InOne, a distributor of electronic and component test equipment, said customers are “settling down in the U.S.,” with about 35 to 40 percent of customers still making non-compliant products—which they either don’t ship to RoHS areas, or they are medical products or other products that are exempt from the compliance regulations.
However, it is not exactly smooth sailing.
The three biggest problems are technical issues, such as the reliability of lead-free products, keeping up with dual processes that serve the compliant and noncompliant markets, and keeping the documentation straight in case of an audit, noted Bender.
Shafer agreed, adding that information technology (IT) and manpower costs go up with dual inventories and dual product lines, documentation needed in case of product/materials audits and additional internal testing processes to show products meet testing standards.
The daunting auditing process has seen some help, namely in the form of IPC 1752—a data standard for the materials declaration portion of RoHS compliance. Created by the National Institute of Standards and Technology (NIST) and International Electronics Manufacturing Initiative (iNEMI), among others, it provides a means of tracking and disclosing the amounts of the six restricted substances.
Because of possible product quality problems for items made with lead-free solder, quality control/quality assurance could take upwards of five years, which is why some types of products are exempt. Any potential failures in medical devices could be catastrophic, so they need extensive testing before they move to becoming RoHS compliant.
Low-lead solders have a higher melting point (up to 260°C versus 180°C), which means companies need to make adjustments to equipment and components to ensure they can handle the higher temperatures. Using lead-free solder means companies need to retool their assembly lines, which adds additional expenses.
Engineering costs can shoot up if companies have to invest money in turning around a noncompliant legacy product even though it has been on the market for 20 years. Such operations, Shafer commented, “can cost millions of dollars.”
“The best thing for the industry would be a harmonization of all the RoHS compliance regulations,” added Bender
China is looking to put out a catalog of products late this year or early 2008, but it has missed several deadlines already. The lack of a firm deadline makes RoHS implementation problematic for U.S. manufacturers.
Even within the EU, enforcement is left up to the individual countries. Comparing EU and China regulations, you have labeling in China, products in the EU. China doesn’t have exemptions, but the EU does. Add to that the piecemeal implementation of individual states in the U.S. and the simple act of trying to comply becomes difficult.
According to Shafer, “the patchwork system from individual states is cumbersome for industry.” He adds that other countries send products to the U.S., further necessitating the need for a standard system, which is going to happen.
A year later, RoHS compliance is more of a work-in-progress than a success story, but the governments have been working with the manufacturing companies that, through due diligence, can show that they are at least putting forth the effort to be compliant.
